Tag Archives: USEPA

EPA UST Office Address Change

Effective January 19, 2016, EPA’s Office of Underground Storage Tanks will be located in the Ronald Reagan Building, which is part of the Federal Triangle Complex in Washington, D.C.

EPA’s Office of Underground Storage Tanks (OUST) has moved from its Arlington, Virginia location to the Ronald Reagan Building in Washington, D.C. The new address: Office of Underground Storage Tanks, US EPA, 1200 Pennsylvania Avenue, NW, Mail Code 5401R, Washington, D.C. 20460.  The email addresses of the OUST staff and UST website www.epa.gov/ust, remain the same. You can access OUST employee’s phone numbers through the headquarters contact section on the OUST website http://www.epa.gov/ust/underground-storage-tank-ust-contacts .

UST Secondary Containment and Interstitial Monitoring Requirements

Are you responsible for ensuring site or corporate environmental compliance or for implementing a site environmental management system that includes fueling systems? Whether you’re an environmental manager, a plant engineer, plant/general manager, facility manager, site manager or other role, if you’re involved with underground fuel storage tanks, the new rules regarding secondary containment should be of interest.

Federal UST Secondary Containment and Interstitial Monitoring Requirements

The 1988 requirement and criteria required secondary containment and interstitial monitoring for hazardous substance tanks only (280.42). The EPA is implementing secondary containment with interstitial monitoring and under-dispenser containment (UDC) as additional measures to protect groundwater. States that have already implemented secondary containment regulations that meet or exceed the federal regulations will not have to change their requirements. There are significant changes to the federal requirements and implementation which are summarized below. The implementation timeframe for secondary containment is 180 days. States with approved programs still have three years to reapply, and depending on which state you are in, you may still be governed by the state program rather than the EPA regulations.

Owners and operators are required to install tank and piping secondary containment that will contain regulated substances leaked from the primary containment until they are detected and removed and that will prevent the release of regulated substances to the environment at any time during the operational life of the UST system, and must be  monitored for leaks at least once every 30 days using interstitial monitoring.

NEW INSTALLS and REPLACING Tanks and Piping

Owners and operators are now required to install secondary containment and interstitial monitoring for ALL (including petroleum) new and replaced tanks and piping. There are still some exceptions like safe suction piping and piping associated with field-constructed tanks over 50k gallons, and airport hydrant systems.

REPAIRING Piping

Owners and operators must replace the entire piping run when 50% or more of the piping (excluding connectors) is removed and other piping is installed.

NEW DISPENSERS

All new dispensers need to have under-dispenser containment.

Interstitial Monitoring

Interstitial Monitoring of new and replaced secondarily contained tanks and piping must occur at least once every 30 days as a release detection requirement.

The EPA reviewed data from release sites and the higher number of releases from single walled tanks and piping when compared to secondarily contained systems was considered in the decision for new requirements to prevent regulated substances from reaching the environment and ensure a consistent level of environmental protection for regulated USTs across the USA.

 

TAIT pre-development work

Tait & Associates and Tait Environmental Services (collectively TAIT) both worked on the Standard Pacific Greenwood at Tustin Legacy project. The environmental work that we did prior to the new and vibrant community that is being developed in Orange County included the Phase I Environmental Site Assessment, as well as environmental soil sampling to screen areas of the former military base that had been used for agriculture, military uses, and previously contained underground storage tanks to confirm that the soil met residential environmental standards. TAIT also closed an abandoned well that was discovered during construction, and evaluated the environmental conditions of soil to be imported during grading to ensure that it met residential environmental standards. Drive by and take a look at the new models that are now open! Here is a copy of the Grand Opening Announcement.

Contact Us for more information regarding our survey and planning, permitting and environmental services. We look forward to hearing from you and discussing your projects!
Standard Pacific Greenwood at Tustin Legacy Grand Opening Announcement

EPA Logo Seal

EPA Pushes Back Final Regulation on USTs to Fall 2014

Looking for updates on the EPA UST Regulations?

We expect to hear more later this year. Here is an article that explains more. Copied from: http://pcmala.org/2014/04/epa-pushes-back-final-regulation-on-usts-to-fall-2014/ TAIT’s 50 year experience with USTs and all fuel system related regulations and work can help answer many questions for you. Reach out to us for additional information.

EPA Logo Seal

EPA Pushes Back Final Regulation on USTs to Fall 2014

By Anthony AdragnaBloomberg ReportApril 17 (BNA) — The Environmental Protection Agency now expects to finalize regulations in fall 2014 expanding monitoring and inspection requirements for certain underground storage tanks, and will take into account comments on the potential impacts on small businesses as it finalizes the rule, the agency has told Bloomberg BNA.

“We consciously developed our 2011 proposed underground storage tank (UST) regulation to avoid provisions that would require costly retrofits to UST systems,” the agency said April 16. “We are carefully considering all of the comments as we develop the final UST regulation.”

Industry groups and members of Congress have consistently and repeatedly criticized the proposed regulation as underestimating the compliance costs and impacts it would have on small businesses (74 DER A-21, 4/18/12).

EPA proposed revisions to underground storage tank requirements in November 2011 and previously said it expected to finalize the regulations in summer 2014. The proposed rule would apply to tanks holding petroleum or hazardous chemicals that are regulated under Subtitle I of the Resource Conservation and Recovery Act. Tanks regulated under Subtitle C of RCRA would not be affected.

According to the agency, there are more than 590,000 underground storage tanks around the country at 210,000 sites. Compliance costs for the proposed rule were $210 million, according to the regulatory impact analysis, but it said the regulation would lead to $300 million to $740 million in annual avoided remediation costs.

The 2011 proposed rule (76 Fed. Reg. 71,708) would create rules for backup containment of the substances in tanks and extend training requirements to more tank operators and owners. EPA says the proposed rule would enable better prevention and detection of leaks in storage tanks, which can cause groundwater contamination.

If finalized, the rule would be the first major revision to federal underground storage tank regulations since 1988.

Longstanding Concerns About Cost

Despite EPA assurances that it had taken into account the impact the proposed rule would have on small businesses, both industry groups and Congress have adamantly disagreed.

The Petroleum Marketers Association of America says EPA’s estimate of $900 in average annual compliance costs per facility is drastically wrong. The group estimates annual compliance costs would actually be $6,100.

Bipartisan groups of 11 senators and 58 House members sent separate letters in July 2013 raising concerns about the cost of the proposed regulation (144 DER A-31, 7/26/13).

“We are concerned that the Agency’s estimated annualized compliance costs of $900 may be significantly underestimated,” the Senate letter said.

TCEQ Publishes Changes Coming for Stage II Vapor Recovery Systems

The TCEQ – Texas Commission on Environmental Quality‘s publication The Advocate – writing for and about small businesses and local governments affected by environmental regulations published this update regarding the removal of Stage II Vapor Recovery equipment. The rules are written, but are awaiting approval by the EPA. Removal will not begin until a minimum of 30 days after approval. Even with approval to remove the equipment, costs may restrict many owner/operators of fuel dispensing facilities to retain the equipment they have.

TCEQ Publication "The Advocate" for and about small business and local governments affected by environmental regulationsWhen the Federal Clean Air Act was written, it prescribed stage II vapor recovery systems be used until onboard vapor recovery canisters on vehicles were in widespread use. EPA has determined that onboard canisters on vehicles are now in widespread use, which will allow states to develop a procedure for removing or decommissioning stage II systems. The procedure must be approved by the EPA.

The TCEQ has completed revising the rules and they are being reviewed by the EPA. Decommissioning may not begin until 30 days after the EPA approves the modified TCEQ rules. We have been working closely with EPA in this process and we expect the EPA to approve the TCEQ rules sometime in the first half of 2014. In the meantime, you must maintain Stage II vapor recovery system equipment and testing.

Information will be sent to all owners and operators when the EPA approves the TCEQ rules. The updated information will be available online.

You can receive updates by e-mail: on the TCEQ home page, click on “sign up for e-mail updates” and after logging in, click on “Regulatory Announcements for Small Businesses and Local Governments.”

If you have any questions about Stage II Vapor Recovery requirements in Texas or other states, Contact Us to learn more. Our Regulatory Affairs Manager, Brian Harmon is a subject matter expert and will be happy to help answer questions or address scenarios where you may want to make changes at your facilities. TAIT has experience at all levels with Stage II Vapor Recovery Systems.

Previous Blogs:

TCEQ & Decommissioning Stage II

TCEQ Proposing to Decommision Stage II Vapor Recovery

Has Your State Waived Stage II Vapor Recovery Requirements?

EPA Proposes Public Comment Period for RFS – Renewable Fuel Standards

FOR IMMEDIATE RELEASE
November 15, 2013

EPA Proposes 2014 Renewable Fuel Standards

Proposal Seeks Input to Address “E10 Blend Wall,” Reaffirms Commitment to Biofuels

WASHINGTON – The U.S. Environmental Protection Agency (EPA) today proposed for public comment the levels of renewable fuels to be blended into gasoline and diesel as required by Congress under the Energy Independence and Security Act of 2007. Developed with input from the U.S. Department of Energy and U.S. Department of Agriculture, the proposal seeks public input on annual volume requirements for renewable fuels in all motor vehicle gasoline and diesel produced or imported by the United States in 2014. The proposal seeks to put the Renewable Fuel Standard (RFS) program on a steady path forward – ensuring the continued long-term growth of the renewable fuel industry – while seeking input on different approaches to address the “E10 blend wall.”

“Biofuels are a key part of the Obama Administration’s “all of the above” energy strategy, helping to reduce our dependence on foreign oil, cut carbon pollution and create jobs,” said EPA Administrator Gina McCarthy. “We have made great progress in recent years, and EPA continues to support the RFS goal of increasing biofuel production and use. We look forward to working with all stakeholders to develop a final rule that maintains the strength and promise of the RFS program.”

The proposal discusses a variety of approaches for setting the 2014 standards, and includes a number of production and consumption ranges for key categories of biofuel covered by the RFS program. The proposal seeks comment on a range of total renewable fuel volumes for 2014 and proposes a level within that range of 15.21 billion gallons. Specifically, EPA is seeking comment on the following proposed volumes:

Category

Proposed   Volume a

Range

Cellulosic   biofuel

17 mill   gal

8-30   million gallons

Biomass-based   diesel

1.28   bill gal

1.28   billion gallons

Advanced   biofuel

2.20   bill gal

2.0-2.51   billion gallons

Renewable   fuel

15.21   bill gal

15.00-15.52   billion gallons

aAll volumes are   ethanol-equivalent, except for biomass-based diesel which is actual

 

Nearly all gasoline sold in the U.S. is now “E10,” which is fuel with up to 10 percent ethanol. Production of renewable fuels has been growing rapidly in recent years. At the same time, advances in vehicle fuel economy and other economic factors have pushed gasoline consumption far lower than what was expected when Congress passed the Renewable Fuel Standard in 2007. As a result, we are now at the “E10 blend wall,” the point at which the E10 fuel pool is saturated with ethanol. If gasoline demand continues to decline, as currently forecast, continuing growth in the use of ethanol will require greater use of higher ethanol blends such as E15 and E85.

The Obama Administration has taken a number of steps to allow or encourage the use of these higher ethanol blends. In 2010, EPA approved E15 for use in vehicles newer than model year 2001 and developed labeling rules to enable retailers to market E15. In addition, since 2011, USDA has made funding available through the Rural Energy for America Program to support deployment of “flex-fuel” pumps that can dispense a range of ethanol blends. The 2014 proposal seeks input on what additional actions could be taken by government and industry to help overcome current market challenges, and to minimize the need for adjustments in the statutory renewable fuel volume requirements in the future. Looking forward, the proposal clearly indicates that growth in capacity for ethanol consumption would continuously be reflected in the standards set beyond 2014. EPA looks forward to further engagement and additional information from stakeholders as the agency works in consultation with the Departments of Agriculture and Energy toward the development of a final rule.

The renewable fuels program was developed by Congress in an effort to reduce greenhouse gas emissions and expand the nation’s renewable fuels sector while reducing reliance on foreign oil. The standards determine how much renewable fuel a refiner or importer is responsible for, and are the standards designed to achieve the national volumes for each type of renewable fuel.

Today, in a separate action, EPA is also seeking comment on petitions for a waiver of the renewable fuel standards that would apply in 2014. EPA expects that a determination on the substance of the petitions will be issued at the same time that EPA issues a final rule establishing the 2014 RFS.

Once the proposal is published in the Federal Register, it will be open to a 60-day public comment period.

More information on the standards and regulations: http://www.epa.gov/otaq/fuels/renewablefuels/regulations.htm

More information on renewable fuels: http://www.epa.gov/otaq/fuels/renewablefuels/index.htm

 

From the Petroleum Equipment Institute:

The U.S. Environmental Protection Agency (EPA) on November 15 proposed for public comment the 2014 levels of renewable fuels to be blended into gasoline and diesel as required by Congress under the Energy Independence and Security Act of 2007.

The proposal would lower the 2014 renewable biofuel mandate from 18.15 billion gallons to a range of 15 billion to 15.52 billion gallons. EPA’s recommended target of 15.21 billion gallons is within the proposed range. That includes 13.01 billion gallons of corn ethanol and 2.20 billion gallons of biodiesel and advanced biofuels.  The corn ethanol target of 13 billion gallons represents almost exactly 10 percent of the gasoline consumption forecast by the U.S. Energy Information Administration for next year. EPA also proposed changes for cellulosic biofuels, with a range between 8 million and 30 million gallons and a recommended target of 17 million gallons.

The proposed 2014 biofuels blending mandate of 15.21 billion gallons is down from the 16.55 billion gallon target finalized for 2013, and 14 percent lower than the original 2014 goal envisioned by Congress. The Renewable Fuel Standard (RFS) requires annually increasing amounts of biofuels to be added into U.S. transportation fuel supplies, to a total of 36 billion gallons in 2022.

This marks the first time in the history of the RFS that EPA has proposed to scale back the government’s overall biofuel blending target for the forthcoming year. If the proposed targets become law, the biofuels markets will stagnate with no growth expected in the foreseeable future. The bottom line for petroleum marketers is that E10—the blend sold in almost all gasoline stations in the U.S. today—will not be tampered with, but that 15-percent (E15) and 85-percent (E85) ethanol blends primarily will be sold as niche or regional products.

The proposal is subject to a 60-day comment period, and could later be changed.

New Hawaii UST regulations

New Hawaii UST regulations

Program’s new UST rules went into effect on August 9, 2013

The State of Hawaii’s Underground Storage Tank (UST) Program’s new UST rules went into effect on August 9, 2013. Some of the changes are specified below, and many more are listed on the Summary of Changes. If you have any questions about the regulations, Contact Us now to ensure you are and will be staying in compliance.

Class A, B, and C operators need to be trained, certified, and designated by December 9, 2013. Hawaii UST Regulation HAR 11-281-46 requires owners and operators to submit the Initial UST Operator Designation Form which lists the Class A and B Operators designated for each UST site within 120 days of December 9, 2013.

Hawaii Department of Health and State Seal logos

The New regulations include:

  • Annual sump testing must be conducted during your next scheduled annual maintenance.

  • All USTs or UST systems installed on or after the effective date of the rules must be provided with secondary containment (be double walled) AND use interstitial monitoring for release detection on the tank(s) and piping. If a portion of single walled piping is replaced, the replaced portion must be provided with secondary containment and interstitial monitoring. If you have any questions regarding these requirements, contact us – TAIT provides tank services and consulting and we are happy to help explain this in more detail.

  • Permits for UST Systems will be required within three years for those facilities that still do not have one yet. Permits for operating shall be submitted on the Application for an Underground Storage Tank Permit form with a $150 fee and will be effective for five (5) years, then will require renewal.

  • Retraining for Class C Operators will be required annually. Retraining for Class A and B operators will be required every 5 years. TAIT and UST Training offer these training courses online and can offer classroom courses as required for large groups. Contact us for more information.

Additional resources: Summary of Changes, Hawaii Administrative Rules Title 11 Chapter 281, the letter from Steven Y.K. Chang, Hawaii’s Chief of Solid and Hazardous Waste Branch regarding the Energy Policy Act of 2005, upcoming requirements and Summary of USTs in HI. More information about the training, the regulations and UST forms  can all be found on the UST page of Hawaii’s DOH website. The Solid & Hazardous Waste Branch website contains additional information such as their Mission Statement, as well.

In preparing for the test, it will be very helpful to review the Technical Guidance Manual for UST Closure & Release Response which can be viewed and some sections can be downloaded. Be aware that revisions are expected to be made.

TAIT has been installing, working on, testing, repairing, removing and closing tank sites since the 60’s and we do projects in Hawaii on a regular basis. If you have any consulting or contracting needs, Contact Us today. We’d love to help answer questions and/or direct you to any other resources you may need.

 

2013 PEI/NACS Show

2013 PEI/NACS show

fotor_(35)

Dennis Tweedy, Billy Watroba and Melanie Nelson attended the NACS show this year, and were joined by a close subcontractor of ours, Katie Seaborn from American Containment Services, Inc.

The 2013 PEI/NACS show, the biggest exposition of fuel handling equipment in the world, lasted from October 12-15 in Atlanta, Georgia. This was the largest NACS show in their history, with 1,050 companies in a attendance making it the 48th largest trade show this year. Over 20,000 people gathered to view and buy the latest advances not only in the convenience store industry, but also in the petroleum business. Every year PEI members convene to discuss, display, and market innovative technologies and services, keeping the industry on the cutting edge. As a bonus, the connections made throughout the convention help to expand and improve businesses, which leads to a greater, more efficient petroleum industry, and where better to have it than in the middle of the #1 buying show in the country. The educational sessions at the NACS show provided extensive information about the highly competitive and illustrious convenience industry. Topics covered in these sessions included:FPImage(10)

  • traditional vs. digital marketing
  • cyberespionage
  • good financing
  • data-driven product positioning
  • the impacts of health care reform
  • customer engagement
  • social media, and much more!

To read more about the topics covered in these sessions visit NACS Educational Sessions, and to learn more about the PEI/NACS Show visit their website. Click here to learn more about the Petroleum Equipment Institute (PEI). For those who are interested, the  following is a video preview of what the PEI/NACS show is all about:

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Successful Designated Operator Program – Contact us to Request a Presentation

Tim Ericsen, COO of Tait Environmental Services, featured in the “O&A” Oil &Automotive Marketing News – for presenting “Contracted Designated Operator – Managing a Successful Program” at the 2013 Pacific Oil Conference in Los Angeles California September 3-5. Here are images from the article:

Newspaper Cover Image

Tim Ericsen, COO of Tait Environmental Services, featured in the "O&A" Oil &Automotive Marketing News - for presenting "Contracted Designated Operator - Managing a Successful Program" at the 2013 Pacific Oil Conference in Los Angeles California September 3-5.

Article Title

54th Annual Pacific Oil Conference Heading for L.A. Live

Article Title Page - Tim Ericsen, COO of Tait Environmental Services, featured in the "O&A" Oil &Automotive Marketing News - for presenting "Contracted Designated Operator - Managing a Successful Program" at the 2013 Pacific Oil Conference in Los Angeles California September 3-5.

 

 

Tim featured in the article

Tim Ericsen, COO of Tait Environmental Services, featured in the O&A Marketing News

Tim’s Title Slide

Contracted Designated Operator – Managing a Successful Program

Contracted Designated Operator - Managing a Successful Program by Tim Ericsen, COO Tait Environmental Services

Example Slide from the Presentation

Common Errors and Omissions

Example Slide - Common Errors - Expired Designated Operator Certification

 
Example Slide Common Errors portion of the presentation: Expired Designated Operator Certification

To request this presentation at your event, contact Tim Ericsen. For any questions about our DUSTO program and the similar Operator Inspections TAIT performs throughout the US, contact us today! TAIT is pleased to serve you in either capacity, and we do much more.

TAIT in the News

TAIT is in the News, again! Here are some pictures and articles where TAIT projects and associates are being featured.

Spetember 2013

COO Tim Ericsen speaks regarding DUSTO program – featured in the O&A Marketing News article about the Pacific Oil Conference.

Tim Ericsen, COO of Tait Environmental Services, featured in the O&A Marketing News

Tim Ericsen, COO of Tait Environmental Services, featured in the “O&A” Oil &Automotive Marketing News – for presenting “Contracted Designated Operator – Managing a Successful Program” at the 2013 Pacific Oil Conference in Los Angeles California September 3-5.